Federal
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August 22, 2025
Canada To Toss Tariffs On US Goods Under USMCA
The Canadian government will remove retaliatory tariffs on U.S. goods that comply with the United States-Mexico-Canada Agreement, excluding steel, aluminum and automobiles, in a move aimed at jump-starting trade talks akin to an exemption made by the U.S. government, Canada's prime minister said Friday.
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August 22, 2025
Tribe Member Can't Discharge Tax Debt, 10th Circ. Affirms
An Oklahoma federal court correctly affirmed a bankruptcy court's refusal to reopen a case brought by a member of the Muscogee Creek Nation who claimed his tax debt should have been discharged in bankruptcy, the Tenth Circuit said.
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August 22, 2025
Taxation With Representation: Kirkland, Weil, Fried Frank
In this week's Taxation With Representation, private equity firm Thoma Bravo buys human resources software provider Dayforce Inc. in a take-private deal, Lowe's buys Foundation Building Materials, Nexstar Media Group Inc. acquires fellow media company Tegna Inc., and Soho House & Co. Inc. inks a take-private deal with hotel operator MCR.
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August 22, 2025
Michigan Judge Gives Initial OK To Tax Foreclosure Deal
A Michigan federal judge has granted preliminary approval to a settlement that would allow former property owners to receive the surplus profits they allege county treasurers made selling their tax-delinquent properties.
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August 22, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included proposed rules that would change its system of business classification for employees hoping to exclude fringe benefits and employee discounts from their gross income.
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August 22, 2025
Treasury Doubles Statutory Value Of Clean Energy Credit
The U.S. Department of the Treasury is nearly doubling the statutory value of an income tax credit for producing electricity in line with a regularly scheduled increase tied to inflation, according to a Friday notice.
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August 22, 2025
IRS Guidance Sparks Mixed Reaction For Solar, Wind Projects
The IRS recently narrowed the way large solar and wind energy development projects can set their construction start dates to qualify for certain tax credits, a change offering relief for some developers but new hurdles for others depending on the stage, type and size of the project.
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August 21, 2025
Tax Court Says Civil Fraud Penalty Cases Don't Require Juries
The U.S. Tax Court rejected Thursday a Mississippi partnership's bid, based on the Supreme Court's landmark 2024 decision requiring a jury to adjudicate common law fraud penalties, to dismiss civil fraud penalties the IRS imposed on a conservation easement transaction.
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August 21, 2025
Man Who Hid Account From Wife Owes FBAR Fines, US Says
A claim by the owner of a check-cashing business that he only meant to hide a foreign bank account from his wife during divorce proceedings doesn't excuse his failure to report the money to the Internal Revenue Service, the U.S. told a California federal court.
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August 21, 2025
EU, US Agree To Eliminate Industrial Tariffs
The European Union and the U.S. have agreed on new terms to the trade agreement to eliminate EU tariffs on U.S. industrial products and implement a 15% U.S. tariff cap for most other sectors, according to a joint statement issued Thursday.
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August 21, 2025
Treasury Gets New Acting International Tax Counsel
A deputy international tax counsel for the U.S. Department of the Treasury has been elevated to serve as acting counsel, he said in a post on LinkedIn.
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August 21, 2025
IRS Asks For Input On Free Filing Programs
The Internal Revenue Service is surveying the public on tax preparation and filing as part of efforts to prepare a report for Congress on key issues surrounding free tax filing options, the agency said Thursday.
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August 21, 2025
Gov't Shrugs Off Sentencing Errors, IRS Leaker Tells DC Circ.
The IRS contractor appealing his five-year prison sentence for leaking thousands of wealthy people's tax returns to the media accused the U.S. of glossing over sentencing errors that unfairly burdened him with "the harshest sentence possible," he told the D.C. Circuit.
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August 21, 2025
G7 Deal May Undermine Global Minimum Tax Enforcement
The U.S. government's agreement with the Group of Seven nations to effectively exempt American companies from the 15% global minimum tax may hollow out enforcement of the international regime, in part because other multinational corporations may pursue similar treatment.
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August 20, 2025
Gov't Asks 8th Circ. To Ignore 2nd Circ. Tax Deadline Ruling
A government attorney seeking to stop a couple from challenging their tax bill in the U.S. Tax Court urged the Eighth Circuit not to follow the Second Circuit's recent determination that the 90-day petition filing deadline is flexible, saying that decision split from long-held precedent.
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August 20, 2025
Fla. Man Who Evaded $7M In Federal Taxes Gets Probation
A Florida investor who admitted to cheating the Internal Revenue Service out of $7 million in taxes was sentenced Wednesday to probation after telling a federal judge he suffers from serious health issues, including Stage 4 kidney cancer and early-onset dementia.
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August 20, 2025
Texas Plastics Co. Says Captive Insurance Program Legit
A plastics manufacturer's captive insurance program to cover itself from various industrial and commercial risks was set up for legitimate reasons, the company told a Texas federal court in a bid to restore a tax deduction the IRS had denied on its premiums.
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August 20, 2025
Morris Manning Faces $5M Ga. RICO Suit Over Tax Strategy
Morris Manning & Martin LLP is facing allegations of racketeering and tax fraud in a suit brought in Georgia state court by three investors that names a number of professional services firms.
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August 20, 2025
IRS To Nix Recent Rules On Disregarded Foreign Payments
The U.S. Treasury Department and IRS said Wednesday that they're planning to remove rules issued in January that would have forced companies to recognize income from payments that are disregarded for U.S. taxes yet reduce income in a foreign jurisdiction, a move prompted by criticism from businesses.
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August 20, 2025
Nutter Welcomes Tax Atty In NY From Fox Horan
Less than a month after announcing it had grown its ranks by 8% with the addition of 13 attorneys in three states, Nutter McClennen & Fish LLP said earlier this week that it has hired a New York-based tax attorney from Fox Horan & Camerini LLP.
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August 20, 2025
IRS Lost Lien In Bankruptcy, Man Says In $28M Tax Battle
The Internal Revenue Service jettisoned any federal tax lien it claims to have against a man by filing an unsecured claim in his bankruptcy case, he told a Florida federal court Wednesday in response to the government's $28 million lawsuit against him.
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August 19, 2025
IRS To Float Rules Aimed At Easing Corporate Moves To US
The IRS announced plans Tuesday to propose regulations that would make it easier for publicly traded foreign corporations that own U.S. real estate to move their official base to the U.S. without facing unexpected tax issues.
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August 19, 2025
IRS Told To Explain Granting $142M Contract Without Bids
The IRS must explain why it thinks an executive order mandating electronic tax payments required it to skip the competitive bidding process in awarding a $142 million contract for scanning and digitizing incoming tax filings, the Court of Federal Claims said.
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August 19, 2025
Reasoning For IRS Firings Clashes With Reality, TIGTA Says
Probationary workers at the Internal Revenue Service who were told earlier this year that they were fired for performance had been rated highly or had not been there long enough to be evaluated, according to a report Tuesday by the Treasury Inspector General for Tax Administration.
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August 19, 2025
Fed. Circ. Won't Revisit Steel Duties On German Companies
The Federal Circuit denied Tuesday a request for it to reconsider a precedential opinion upholding steel duties on German companies imposed after the U.S. Department of Commerce applied adverse facts available in an antidumping investigation.
Expert Analysis
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Justices' False Statement Ruling Curbs Half-Truth Liability
The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.
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Perfecting Security Interests In Renewable Energy Tax Credits
The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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Why NY May Want To Reconsider Its LLC Transparency Law
Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.
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IRS Scrutiny May Underlie Move Away From NIL Collectives
The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.